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Privacy Policy

How Spinly, operated by DAK Enterprises LLC, handles your information — a short answer, and a long one.

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Privacy Policy

Last Updated: July 16, 2026 | Effective Date: July 16, 2026

The Short Version

Spinly is a decision-wheel app. Everything you create — wheel names, slice labels, colors, spin history — is stored on your device in Spinly's local database. We do not operate any server that receives your data. We do not use analytics, advertising, crash reporting, or tracking SDKs. We do not collect your name, email, phone number, location, contacts, photos, camera, microphone, or advertising identifier. We do not sell, rent, or trade any information about you.

The long version below spells this out in detail and covers the legal disclosures required for the App Store and applicable privacy laws.

1. Introduction

This Privacy Policy describes how Spinly ("we," "us," "our," or the "App"), operated by DAK Enterprises LLC, handles information when you use the App on iOS or iPadOS. By downloading, installing, or using Spinly, you acknowledge that you have read, understood, and agree to this Privacy Policy.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT INSTALL OR USE THE APP.

2. Information Stored On Your Device

Spinly stores the following information locally on your device inside the App's private sandboxed storage. This storage is protected by iOS's standard app sandbox and is not accessible to other apps or to us.

2.1 Wheel Data

2.2 App Preferences

2.3 System-Managed Data (Not Accessed By Us)

iOS itself may maintain records associated with any app, such as background refresh state, notification permission status, and standard system logs. These records are managed by iOS and not accessed by DAK Enterprises LLC.

3. Information We Do NOT Collect

We want to be explicit about the categories of data that Spinly does not touch:

4. How We Use Information

Because we do not receive your wheel data or any personal information, we do not "use" that information in the traditional sense. The App uses the data you enter on your device solely to:

All of this processing happens on your device. Nothing is transmitted to DAK Enterprises LLC.

5. Data Sharing and Disclosure

5.1 No Sharing With Us

Because the App does not transmit data to any DAK Enterprises server, there is nothing for us to share. We do not have access to your wheels.

5.2 No Sale of Personal Information

WE DO NOT SELL, RENT, TRADE, OR OTHERWISE DISCLOSE ANY PERSONAL INFORMATION TO THIRD PARTIES FOR THEIR MARKETING OR ADVERTISING PURPOSES.

5.3 Apple

Because Spinly is distributed through the Apple App Store, Apple may collect certain information related to your download, installation, purchases, and use of the App under Apple's own privacy practices. That information flows between you and Apple; DAK Enterprises LLC receives only limited, aggregated reporting (for example, total downloads or in-app purchase counts) provided by Apple through App Store Connect. See Apple's Privacy Policy for more information.

5.4 Legal Requirements

If we were served with a valid legal process seeking information we hold about a user, we would disclose only information that is actually in our possession. Because the App runs entirely on your device, the information we hold about individual users is generally limited to what Apple has already provided through App Store Connect.

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or part of DAK Enterprises LLC's assets, any information we do hold may be transferred to the acquiring entity, subject to this Privacy Policy.

6. Cloud Sync — Not Currently Enabled

As of the effective date of this Privacy Policy, Spinly does not sync your wheels to iCloud, CloudKit, or any other cloud service. All wheel data lives only on the device where you created it.

We may enable optional iCloud/CloudKit sync in a future version of the App so that your wheels can appear on multiple devices that share the same Apple ID. If and when we enable cloud sync:

7. In-App Purchases

Spinly is free to download and free to try. A one-time, non-consumable in-app purchase — Spinly Unlimited ($1.99 USD) — unlocks the ability to save an unlimited number of wheels; the free tier is limited to three saved wheels. All purchase processing, billing, and refunds are handled by Apple through the App Store under Apple's standard payment terms. DAK Enterprises LLC does not receive or store your payment card information. Apple provides us only with aggregated purchase reporting through App Store Connect.

Purchases can be restored on any device signed in to the same Apple ID using the App's built-in Restore Purchases action or the standard Apple restore flow.

8. Data Storage and Security

8.1 Where Your Data Lives

All wheel data and preferences are stored on your device inside Spinly's private application sandbox using Apple's SwiftData framework backed by SQLite. This storage is protected by iOS's standard app sandbox and file protection mechanisms.

8.2 Security Measures

Because the App does not transmit your data over any network, the network attack surface for Spinly data is essentially the security of your own device. We rely on Apple's platform security — device passcode/biometric protection, iOS sandboxing, hardware-backed encryption, and system-level file protection — to safeguard the data at rest on your device.

8.3 No Guarantee

NO METHOD OF DIGITAL STORAGE IS 100% SECURE. IF YOUR DEVICE IS LOST, STOLEN, JAILBROKEN, OR OTHERWISE COMPROMISED, THE DATA STORED ON IT — INCLUDING SPINLY WHEELS — MAY BECOME ACCESSIBLE TO OTHERS. WE CANNOT GUARANTEE ABSOLUTE SECURITY OF DATA STORED ON YOUR DEVICE.

9. Data Retention

Because we do not hold your data, there is nothing on our side to retain. Wheel data you create in the App is retained on your device until you delete individual wheels, delete the App, or reset your device. Deleting the App will remove its sandboxed storage and permanently delete all of your Spinly data on that device.

10. Third-Party Services

Spinly does not integrate with or send data to any third-party analytics, advertising, crash reporting, or backend service. The App relies only on Apple-provided platform services (including SwiftData, StoreKit, Core Haptics, and AVFoundation) to function.

The App is distributed exclusively through the Apple App Store. Your download, installation, and any in-app purchases are subject to Apple's Privacy Policy and Apple's App Store Terms.

11. Your Rights and Choices

11.1 Access

You can access every piece of data Spinly stores about you by simply opening the App on your device. That is all of it.

11.2 Correction

You can edit or correct any wheel you have created directly within the App.

11.3 Deletion

You can delete individual wheels within the App. To delete all Spinly data at once, delete the App from your device. Deleting the App removes its private sandboxed storage and permanently deletes all associated data on that device.

11.4 Notification Preferences

You may control any notification permissions for Spinly at any time through Settings → Notifications → Spinly on your device.

12. Children's Privacy

Spinly is a general-audience decision-wheel app. It is not directed to children under the age of 13, and we do not knowingly collect any personal information from children. The App has no accounts, no messaging, no user-generated content sharing, and no analytics that could identify a child. If you are a parent or guardian and believe your child has provided information to us that requires attention, please contact us at [email protected].

13. International Data

Because Spinly stores your data on your device rather than on a central server, no international transfer of your wheel data occurs. To the extent that Apple stores App Store account information, purchase records, or crash logs on your behalf, that data may be transferred to and processed in the United States and other countries in which Apple operates, subject to Apple's Privacy Policy.

14. California Privacy Rights (CCPA / CPRA)

California residents have the right to request information about the personal information a business has collected about them, to request deletion of that personal information, to correct inaccuracies, to opt out of the sale or sharing of personal information, and to not be discriminated against for exercising these rights.

Because DAK Enterprises LLC does not collect, receive, sell, or share your personal information through the Spinly app, most of these rights have no operative effect: there is no data on our side to disclose, delete, or opt you out of. You can exercise your right to delete by uninstalling the App from your device. To submit any other request, contact us at [email protected].

15. European Privacy Rights (GDPR / UK GDPR)

For users in the European Economic Area or the United Kingdom, we note that Spinly does not process personal data of EEA/UK residents in a way that establishes DAK Enterprises LLC as a data controller of your wheel data, because that data never leaves your device.

If you nonetheless wish to exercise any GDPR or UK GDPR right — access, rectification, erasure, restriction of processing, portability, objection, or the right to withdraw consent — you may:

16. Disclaimer of Warranties

THE APP IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

USE OF THE APP IS AT YOUR SOLE RISK.

SPINLY IS AN ENTERTAINMENT AND DECISION-ASSIST TOOL. IT IS NOT INTENDED FOR MEDICAL, LEGAL, FINANCIAL, SAFETY-CRITICAL, OR MISSION-CRITICAL USE, OR FOR ANY DECISION WHERE ERROR OR ARBITRARY OUTCOME COULD RESULT IN INJURY, LOSS, OR HARM.

We do not warrant that:

17. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, DAK ENTERPRISES LLC SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO:

OUR TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING FROM OR RELATED TO THE APP OR THIS PRIVACY POLICY SHALL NOT EXCEED THE GREATER OF: TEN UNITED STATES DOLLARS ($10.00 USD), OR THE TOTAL AMOUNT YOU PAID DAK ENTERPRISES LLC FOR THE APP IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE CLAIM.

18. Indemnification

You agree to indemnify, defend, and hold harmless DAK Enterprises LLC, its owners, officers, directors, employees, agents, licensors, and affiliates from and against any claims, demands, actions, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from or related to:

19. Dispute Resolution and Arbitration

19.1 Informal Resolution

Before initiating formal dispute resolution, you agree to contact us at [email protected] and attempt informal resolution in good faith for at least thirty (30) days.

19.2 Binding Arbitration

Any dispute arising from or relating to this Privacy Policy or the App that is not resolved informally shall be resolved by binding arbitration under the Consumer Arbitration Rules of the American Arbitration Association (AAA) in Naples, Florida (or via remote hearing at the arbitrator's discretion). The arbitrator's decision shall be final and binding.

19.3 Class Action Waiver

YOU AGREE TO RESOLVE DISPUTES ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS, CONSOLIDATED, MASS, OR REPRESENTATIVE ACTION OR PROCEEDING.

19.4 Small Claims Exception

Either party may bring an individual action in small claims court if the claim qualifies.

19.5 Opt-Out Right

You may opt out of the arbitration provisions in this Section 19 by sending written notice to [email protected] within thirty (30) days of first accepting this Privacy Policy.

20. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Florida, United States, without regard to conflict of law principles. For any matter not subject to arbitration, you consent to the exclusive jurisdiction of state and federal courts located in Collier County, Florida.

21. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the App, in applicable law, or in our practices (for example, if we enable optional iCloud sync as described in Section 6). Changes become effective when the updated policy is posted at https://dakenterprises.dev/spinly/privacy.html. Material changes will be reflected in the "Last Updated" and "Effective Date" fields at the top of this document. Your continued use of the App after changes are posted constitutes acceptance of the updated Privacy Policy.

22. Contact Us

Spinly
Published by DAK Enterprises LLC

Email: [email protected]

23. Acknowledgment

BY INSTALLING OR USING SPINLY, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY, INCLUDING THE ARBITRATION AGREEMENT AND CLASS ACTION WAIVER IN SECTION 19.